Spill Prevention, Control, and Countermeasure Plan (SPCC) | The University of Chicago Environmental Health and Safety

Policy

The University of Chicago shall maintain a Spill Prevention, Control and Countermeasure (SPCC) Plan as required by the United States Environmental Protection Agency (US EPA) to prevent any discharge of oil into or upon navigable water of the United States or adjoining shorelines.

Applicability

This SPCC Policy (the “Policy”) applies to the University of Chicago (the “University”) and University of Chicago Medicine (“UCM”) Hyde Park campuses and Howard Taylor Ricketts Laboratory (“HTRL”) located in Argonne National Laboratories.

The University of Chicago SPCC Plan covers SPCC-covered equipment located in the Hyde Park Campuses of the University and UCM while the HTRL SPCC Plan is specific to SPCC-covered equipment located at HTRL.

Scope

This policy covers oil-containing aboveground bulk storage containers and oil-filled operational equipment with storage capacities of 55 gallons or greater (both hereafter referred to as “SPCC-covered equipment”).

Authority and Responsibility

Environmental Health and Safety (EHS) is responsible for:

Maintaining and facilitating five-year reviews and updates of the University of Chicago and HTRL SPCC Plans;
Periodically auditing monthly SPCC inspections to confirm they are being completed;
Responding to oil spills in University buildings and providing assistance as needed at UCM and HTRL;
Notifying regulatory agencies of releases of oil to the environment from University, UCM, and HTRL;
Facilitating root-cause investigations of oil spills and leaks and conducting follow-up communications with regulatory agencies when required;
Providing training to personnel who are responsible for implementing requirements within the SPCC Plan;
Providing oil spill response kits for SPCC-covered equipment located in University buildings and HTRL as required per the SPCC Plan;
Inspecting and re-stocking oil spill response kits located in University buildings; and
Advising project managers on projects which may be impacted by this Policy or one of the SPCC Plans.

University of Chicago Medicine Environmental Health and Safety (UCM-EHS) is responsible for:

Collaborating with EHS to review and update the University of Chicago SPCC Plan;
Notifying EHS of oil leaks or spills which result in releases to the environment;
Responding to reported incidents according to the UCM "Hazardous Material Emergency Response Plan";
Supplying oil spill response kits for SPCC-covered equipment in UCM buildings as required by the SPCC Plan;
Notifying Physical Plant and construction project managers of the requirements of this Policy and the SPCC Plan for projects which may be impacted by this Policy or the University of Chicago SPCC Plan; and
Coordinating SPCC training for UCM personnel with EHS.

University of Chicago Police Department (“UCPD”) is responsible for:

Paging the EHS On-Call Officer when notified about oil leaks or spills.

Facilities Services - Operations is responsible for:

Completing monthly inspections required by the University of Chicago SPCC Plan for SPCC-covered equipment located in University buildings for which they provide service;
Ensuring monthly SPCC-required inspections assigned to contractors are completed and documentation is made available to EHS upon request;
Coordinating and maintaining records, for the life of the equipment, of tank integrity testing when required by the SPCC Plan and providing copies to EHS;
Providing EHS with copies of SPCC-required inspections and integrity testing results;
Informing EHS prior to installing or modifying SPCC-covered equipment or making any structural or floor layout changes to spaces in which SPCC-covered equipment are located;
Immediately reporting oil leaks or spills to the University of Chicago Police Department (UCPD) to ensure EHS is paged;
Responding to oil spills, when safe to do so, following the procedures described in this Policy;
Notifying EHS when a spill kit has been used to clean spills; and
Completing annual training as required by this Policy and the University of Chicago SPCC Plan.

Physical Plant is responsible for:

Completing SPCC-required inspections in UCM buildings University buildings for which they provide service;
Ensuring monthly SPCC-required inspections assigned to contractors are completed and documentation is made available to EHS upon request;
Inspecting and restocking oil spill response kits in UCM buildings;
Informing EHS prior to installing or modifying SPCC-covered equipment or making any structural or floor layout changes to spaces in which SPCC-covered equipment are located;
Responding to oil leaks or spills according to the UCM "Hazardous Material Emergency Response Plan" for UCM Buildings;
Immediately notifying UCM-EHS of a spill or release of oil into environment;
Immediately notifying UCPD about spills which occur at Kovler Laboratory, Cummings Life Sciences Center (“CLSC”), Donnelly Biological Sciences Learning Center (“BSLC-Donnelley”), Jules F. Knapp Medical Research Center (“BSLC-Knapp”), and Knapp Center for Biomedical Discovery (“KCBD”), to ensure EHS is paged;
Responding to oil spills, when safe to do so, following the procedures described in this Policy when oil spills occur in Kovler Laboratory, CLSC, BSLC-Donnelley, BSLC-Knap, or KCBD; and
Completing annual training as required by this Policy and the University of Chicago SPCC Plan.

Facility Managers are responsible for:

Reporting signs of oil leaks to Facilities Services or Physical Plant.

Project Managers are responsible for:

Reviewing project designs with EHS when scopes include the installation of oil-containing bulk storage containers or oil-filled operational equipment;
Reviewing project designs with EHS when scopes include the modification or removal of SPCC-covered equipment or renovation of spaces in which SPCC-covered equipment are located;
Ensuring project designs comply with the requirements of this Policy and the applicable SPCC Plan; and
Ensuring contractors comply with the applicable SPCC Plan when they are onsite during construction (e.g. storage of project-related oils).

SPCC Plan

The University, UCM, and HTRL are required to maintain SPCC Plans because:

They store oils in excess of 1,320 gallons in SPCC-covered equipment; and
Due to their locations, releases of oils could reasonably be expected to discharge into or upon navigable waters.

Examples of oils located at the University, UCM, and HTRL which are covered by this Policy and the SPCC Plan include:

Petroleum-based fuels, such as gasoline and diesel;
Lubricating and coolant oils;
Metal-working fluids;
Cooking oils and greases; and
Elevator hydraulic oils.

Examples of SPCC-covered equipment include:

Emergency generators;
Fuel storage tanks;
Grease traps;
Drums with capacities of 55 gallons or greater; and
Hydraulic-oil powered elevators.

Per the EPA SPCC regulations, SPCC Plans must be certified by an Illinois-licensed Professional Engineer (PE).

SPCC Plan Components

The University of Chicago and HTRL SPCC Plans shall address the following areas:

A description of the facility’s location, proximity to navigable waterways, and use of oil;
Inventory of SPCC-covered equipment;
Spill history;
Potential spill volumes of the various oil tanks around campus;
Worst-case discharge scenario from each SPCC-covered equipment;
Spill response procedures;
Emergency response procedures;
Emergency phone numbers;
Notification requirements; and
Training requirements.

SPCC Plan Locations

Printed copies of the SPCC Plans will be maintained in the following locations:

EHS office for both the University of Chicago and HTRL SPCC Plans;
The HTRL building engineer office for the HTRL SPCC Plan;
EHS can provide electronic copies of SPCC Plans to employees who submit an email request to safety@uchicago.edu.

Updates to SPCC Plans

EHS will arrange for both SPCC Plans to be reviewed and re-certified by an Illinois-licensed PE at the following frequency:

Every five (5) years; or
Within six months whenever there is a change in facility design, construction, operation, or maintenance that materially affects potential for a discharge (e.g. installation or modification of SPCC-covered equipment or renovation of spaces containing SPCC-covered equipment).

Spill Containment Measures

Passive Measures

SPCC-covered equipment shall be equipped with one of the following passive measures to prevent releases of oil resulting from leaks or spills:

Berms or dikes;
Spill pallets; or
Double-walled tanks.

Where passive measures are not feasible, drains must not be located in close proximity to SPCC-covered equipment or should be protected to prevent oils from entering the sewer.

Spill Kits

Spill response kits will be located in close proximity to each SPCC-covered equipment. At a minimum, these kits will contain:

Oil-absorbing pads, socks, and pillows; and
Personal protective equipment.

Note: Only employees who have completed SPCC training are authorized to use the spill response equipment.

Spill Notification and Response Procedures

The University of Chicago SPCC Plan describes the procedure for responding to oil leaks or spills at the Hyde Park campuses of the University and UCM:

Employees who discover an oil spill or leak in an University building must immediately notify the UCPD;
The UCPD will subsequently notify EHS;
Employees at UCM will follow the notification procedures listed in the “UCM Hazardous Material Emergency Response Plan".
When an oil spill or leak in a UCM building results in a release to the environment, UCM-EHS will immediately notify EHS;
Employees who have been completed SPCC Training are authorized to initiate spill response procedures if it is safe to do so (please refer to the SPCC Plan or the SPCC Training for specific spill response procedures);
EHS will notify regulatory agencies of oil spills or leaks when required by the SPCC Plan; and
EHS will investigate all spills or leaks from SPCC-covered equipment and document findings and corrective actions on UCAIR.

Employees at HTRL will immediately notify UCPD of oil spills or leaks and follow the Argonne National Laboratory emergency response procedures for reporting oil spills or leaks.

SPCC Inspections and Records

Monthly Inspections

SPCC-covered equipment must be inspected monthly to ensure they are in good condition and are not leaking. These monthly inspections must be completed by either:

The departments who maintain the SPCC-covered equipment; or
Contactors hired to maintain SPCC-covered equipment, such as those who service elevators or emergency generators.

Monthly inspections completed by Facilities Services or Physical Plant engineers must adhere to the following requirements:

Inspections must be tracked via their respective work tracking system;
Records of inspections must be retained for at least 3 years; and
Separate work requests must be generated whenever deficiencies are found during the monthly inspection.

Monthly SPCC inspections assigned to contractors must adhere to the following requirements:

Contractors may document the monthly inspections on the SPCC Monthly Inspection Checklist or their own forms, provided they include the same inspection points;
Contractors are not required to submit copies of completed checklists to EHS on a monthly basis but they must be capable of furnishing copies within 24 hours upon request; and
Inspection criteria and recordkeeping requirements must be defined in the contract (please allow EHS to review contracts and requests for proposals for any contract related to maintenance of SPCC-covered equipment or when assigning SPCC monthly inspections to contractors).

Integrity Testing

Currently, none of the SPCC-covered equipment located at the University, UCM, or HTRL require periodic structural integrity testing. However, the SPCC Plan may require integrity testing for future installations of SPCC-covered equipment based on the design specifications and discharge potential.

If required for future installations of SPCC-covered equipment, then Facilities Services and Physical Plant will be responsible for scheduling, funding, and maintaining records of integrity testing and providing electronic copies of the results to EHS. Integrity testing records must be maintained for the life of the tank.

Training

Training on the SPCC Plan covers the following topics:

Oil spill prevention;
Spill containment methods;
Spill response and retrieval methods; and
Applicable oil-pollution prevention regulations.

Training on the SPCC Plan is required for the following employees:

Employees who handle oils covered by the SPCC Plan;
Employees who maintain or operate SPCC-covered equipment;
Supervisors of employees or contractors who handle oils or maintain or operate SPCC-covered equipment; and
Employees who will be involved with the spill response.

Training on the SPCC Plan will be required at the following frequency:

Initially, within 30 days of being assigned duties; and
Annually thereafter.

Projects

Project Design Review

Project managers should review the Floor Drain Safety Considerations document and complete the “Project Planning and Design Review Checklist” when the project scope includes:

Installation of oil-containing bulk storage containers and oil-filled operational equipment;
Modification or removal of SPCC-covered equipment; or
Renovations of spaces in which SPCC-covered equipment are located.

EHS will advise project manager to ensure the project design:

Includes passive containment measures for newly installed oil-containing bulk storage containers and oil-filled operational equipment which will be included in a SPCC Plan; or
Does not increase spill potential when SPCC-covered equipment or the spaces in which they are located are modified.

Project Commissioning

Upon completion of projects which install SPCC-covered equipment, EHS will:

Review the final installation of SPCC-covered equipment to confirm they meet design requirements for passive containment;
Arrange for an Illinois-licensed PE to review the new SPCC-covered equipment and update and re-certify the impacted SPCC Plan; and
Assist Facilities Services or Physical Plant with establishing a monthly SPCC inspection program for the newly installed SPCC-covered equipment.

Project Activities

Contractors must comply with the oil storage, handling, and spill reporting procedures outlined in the applicable SPCC Plan if they will bring SPCC-covered equipment onsite. Upon request from the Project Manager, EHS can provide copies of the SPCC Plans or review the SPCC Plans with contractors. Contractors must submit requests to review the SPCC Plans to the Project Manager.

Guidance Documents

SPCC Summary Sheet

Reviewed: August 2023